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While exiting the paint application plant, I observed a drum inside the north roll <br />up door • the "roll • plant that had •• an inch of what Mr. Karp <br />identified as waste crank case oil floating on what appeared to be water. This <br />drum did not have a label or a tight fitting lid. <br />[OrST01 0111161a_'11116119.6 - -t` - -00 - 0 - • - 0 . <br />A4 <br />We then proceeded to the hazardous waste storage area. Drums of MEK <br />sludge were stored on shelves three levels high. Here I observed eight drums <br />of MEK sludge, identified as such by Mr. Karp., that were not labeled. At this <br />point, Ms. Violett and I left the facility. Ms. Violett and I returned to Interlake Inc. <br />at approximately 1:00 pm to review documents including hazardous waste <br />manifests, waste analysis, contingency plan, training records, and any other <br />relevant documentation relating to the handling of hazardous waste. Mr. Karp <br />furnished me with analytical laboratory analysis for the three waste streams that <br />he has classified as non -hazardous. The analysis appeared to • in <br />accordance with Title 22 for self -classification of a waste. <br />Ms. Violett reviewed the hazardous waste manifests, and Board of EqualizatioM <br />reports. Ms. Violett determined a total of 109.72 tons of hazardous waste wa <br />'I <br />disposed of during 1990. Evergreen Environmental hauled 3.55 tons of wast <br />oil off site. Safety Kleen hauled .5 tons of waste solvent off site. American <br />Environmental (11855 White Rock Road, Rancho Cordova, CA, 95670) haule <br />105.7 tons of MEK and paint waste off site. <br />Ms. Violett and I reviewed the employee training records and contingency plan <br />which lacked the following documents and records: <br />The job title for each position at the facility related to hazardous waste <br />management and the name of the employee filling each job. <br />2. A written job description for each position. <br />3. A written description of the type and amount of training that will be given to <br />each person filling a position. <br />4. Records that document the training or job experience required has been <br />given to and completed by facility personnel. <br />P <br />